Dear Paul,
On behalf of the Board and members of Denali Citizens Council, thank you for the opportunity to
comment on the Visitor Facilities Study. Denali Citizens Council (DCC) has been interested and concerned regarding north access proposals since the early 1990s. We are currently following the North Access Reconnaissance Study (NARS), a study that may determine the desirability or feasibility of a north access route into Denali. It is our belief that until the NARS is complete, any other study of northern access will be premature.

The planners in charge of the Facilities Study attended the DCC Spring Dinner this May and gave us an early look at the purpose and focus of the study. At that time and now, we feel that the Visitor Facilities Study is premature. As a result, we are having a difficult time developing answers to the questions you have posed, namely "What types of potential visitor or recreation facilities would you like us to consider?" and "Are there any specific locations we should or should not explore for optional locations for development?"
With the NARS not complete, the answers to these questions would be so hypothetical as to be a poor use of your planners' time.

We are able to answer, at least in part, the third question you posed, "How would any future visitor facilities or recreational opportunities within the study area impact (positively or negatively) your use of this area?" As you know, the Wolf (or Stampede) Townships, in which the state part of this road alignment is located, are mostly roadless at this time. The Stampede Road was actually never used as a public road and is unsuitable for such use, except for the first eight miles, which has been graded and chip sealed. However, the first eight miles is a residential area and the road was improved for that reason, to provide access to residences. Though not all DCC members are residents of this area, the answers of residents deserve special attention.

The Wolf Townships are utilized by members of the local and regional community for various forms of off- road recreation, including hunting, hiking, ATV use, snowmachining, sightseeing, horseback riding, dogsledding, travel to cabin sites and possibly some access by small aircraft. It is these existing uses and their impacts that are the most logical and productive subjects of your study. Leave out the location of parking lots, visitor centers and other hypothetical appliances for a road or railroad that remains hypothetical at best. There are now and will be in the future important impacts from roadless uses in the study area, in both the state and federal portions. The study should concentrate on these existing conditions and should provide guidance for the management of the area as it is, a roadless recreational area.

Following are additional comments and observations regarding this study:
1. The "Stampede Road Alignment," for the purposes of the study, has been improperly defined.
The Stampede Road Alignment ends at the Stampede Mine. This was as far as Earl Pilgrim traveled when he developed the cat track known as the Stampede Road. There is no road between the Stampede Mine and Kantishna and no right of way. Why is the study being framed in this way? Is it the political forces in the State of Alaska and in the federal government that seek to push a northern access all the way to Kantishna? What legal document or Act of Congress has defined the Stampede Road Alignment in this way? If it has, it needs amending. We object to this characterization and we are concerned lest a route all the way to Kantishna will gain legitimacy through this use of language.

2. The National Park Service has never favored northern access into Kantishna.
Statements by Park staff and in NPS planning documents do not favor a northern route into Kantishna. The northern additions were added as habitat and for protection of subsistence. The Wolf Townships were at one time in the history of ANILCA destined to be within the National Park, but were excluded in the final version of the bill. Therefore, facility development in this area really does go against long standing policy, based on knowledge of its importance for wildlife. In the Tanana Basin Plan, the State of Alaska confirmed this primary use for the Wolf Townships. Denali Citizens Council agrees with this long standing agency policy regarding the north side of Denali.

3. Existing uses in the Wolf Townships will need management in order to avoid impairment of resources.
Off-road recreational uses have evolved in the wolf townships, and they reflect the desire of many folks in the area for a slower paced, rural lifestyle. This is a legitimate lifestyle that ought to be protected on the roadless state lands within the study area. However, this roadless recreation must be managed to prevent impairment. Your study can concentrate on collecting data on existing uses and developing best management practices for avoiding impairment.

There are agencies now that deal with management of off road uses. For example, the Rivers and Trails Conservations Assistance program (RTCA) can provide assistance in evaluating ATV impacts, making suggestions for mitigation, and developing citizen-agency partnerships.

Both federal and state portions of the study area can and should be maintained as roadless backcountry. Recreational uses of the lands within the National Park will be covered in its Backcountry Management Plan, currently being developed. The uses on the state lands should be managed through a cooperative effort between state agencies, the Denali Borough and the local citizenry, in consultation with the National Park Service. Please concentrate the North Access Facilities Study upon studying existing uses and making recommendations for management of the study area for long term sustainability as wildlife habitat and for rural, roadless recreation.

Nancy Bale

President, DCC